WE TAKE YOUR PRIVACY SERIOUSLY

When you visit Pronamics’ website, our website hosting provider automatically records certain data about you. Most other websites do too. This data is recorded in a log of accesses and includes the web address you request, the I.P. and domain from which you make the request, the web browser and version you use, your operating system and a record of each page visited.

Pronamics collects your personal information (names, addresses, contact details etc) when you purchase our products or submit a form on our website. Information collected is only used for the primary purpose of providing you with the services we contracted to provide to you. This includes advising you of updates/new software products, providing technical support and administering licenses.

Pronamics will treat all your information in accordance with the Privacy Act 1988, and the application of the relevant Australian Privacy Principles.

Please note that Pronamics will not collect any personal information about your racial or ethnic origin, political opinions or membership of political associations, religious or philosophical beliefs, membership of a professional or trade association or trade union, genetic data, biometric data, health, sexual practices or sexual preferences.

Personal information submitted by the user for administration purposes will not be made available to any third party. There is no requirement for the user to divulge personal information when they access our website or associated entities. However, in order to maintain a level of communication and adhere to the Terms and Conditions, this personal information will be required should the user wish to access the features.

The collection, processing and storage of your personal information by Pronamics is regulated by Australian privacy legislation and, where applicable, the EU’s General Data Protection Regulation (“GDPR”).

For the purposes of the GDPR, we (Pronamics Pty Ltd) are the data controllers in respect of the personal information which we hold about you. As data controllers, we are responsible for determining how we use the personal information which we hold about you.

INFORMATION COLLECTED FROM WITHIN OUR SOFTWARE

In the interests of providing a better service to you for any of Pronamics’ products that you have purchased (“Products”), we may need to access and store some private or personal information.

By accepting the Software Licence Agreement you consent to Pronamics:

• Collecting, storing and processing the personal information that you provide to us
• Creating a database record about you
• Contacting you with information that we think might be of interest to you (unless you have asked us not to)
• Utilising your information for training purposes
• Verifying information submitted by you
• Utilising information submitted by you for internal statistical purposes
• Collecting information for our internal commercial use

Links have been incorporated into our Products and website to assist the user to access further useful information. Utilising the links provided is a personal choice. Third party sites operate under their own privacy policies.

PRODUCT ACTIVATION AND PRONAMICS PRODUCT SELECTOR USE

When you use the Product selector to install your Product or activate the software, Pronamics collects certain information about your device, such as the licence key you have entered and information about the licenced Products to which you have access. Logs about whether a not an installation or activation by you is successful are also kept for auditing purposes.

THE SENDING OF PROGRAM USAGE INFORMATION

Some Pronamics Products give you the ability to voluntarily submit program usage information. This data is sent anonymously and can include the windows you access or the controls you use. This allows Pronamics to internally analyse the areas of the Products regularly use and how they can be improved. Sending usage information is not enabled by default and must be agreed to by each user.

THE SENDING OF ERROR REPORTS

If an error is displayed while using a product, you are able to voluntarily send the log files to Pronamics to report the error. Anonymous device information such as system specifications as well as Pronamics licence information and product version information are collected by Pronamics in order to identify the cause and best method of rectifying the error. Error information is not sent automatically by the application.

Personal details entered in the Your Details tab of the Options window within our Products are appended to error log information generated by the program.

No internal project data is transferred with the error log information.

When error information is sent to Pronamics, either via facsimile, email, web or other means, Pronamics uses this information for the sole purposes of identifying the individual user with the error, corresponding with them, identifying the cause of the error, and for the provision of information regarding resolutions.

LEGAL BASIS FOR PROCESSING

As noted above, in certain circumstances we will process your personal information on the legal basis that you have provided your consent to the processing.

In addition to this, we will process your personal information where this is necessary in order for us: (i) to perform the contract we are about to enter into or have entered into with you; or (ii) to comply with any legal obligation or regulatory requirement imposed on us.

We will also process your personal information where this is necessary for the purposes of our legitimate interests in operating our business correctly, promoting our products and services effectively, developing and improving our products and services and growing / promoting our business.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you require details about the specific lawful ground we are relying on to process your personal information

DISCLOSURE

Pronamics does not take part in “spamming” or direct marketing, and will not disclose collected contact details to any third parties without consent except when required to do so under law or for the purposes of our legitimate interests which may include disclosure to:

• related bodies corporate of Pronamics;
• public authorities;
• professional advisors, including accountants and legal representatives;
• other third party service providers in connection with the operation of the business, such as providers of IT services, hosting services and payment processing services; and
• any third parties to whom Pronamics may choose to sell, transfer or merge parts of its business or assets.

CORRESPONDENCE

Periodically, we may notify our contacts advising of upgrades to existing products, new products and training or other events. You can stop receiving these notifications at any time by sending an email to info@pronamics.com.au with the word “unsubscribe” in the subject line or by calling us on +61 7 3481 9666.

E-MAIL

If you provide us with your e-mail address through our site, that address will only be used for the purposes we disclose to you when you give us your e-mail address. We will not add your e-mail address to a mailing list without your agreement. We will not pass on your e-mail address to third parties. An e-mail that we receive through our Website may be archived or backed up on our server for our own records only. In addition to the content of e-mail messages, we record (as is the standard practice) the date and time of message transmission, when the message was received and opened, the e-mail addresses of the sender, recipients and mail programs.

SECURITY

Safeguarding the privacy of your information is important to us. Pronamics takes all reasonable steps to secure any personal information from unauthorised access including regularly reviewing and updating our security measures in light of technological updates. Additionally, our employees and contractors that we engage to provide services related to our information system are obliged to protect the confidentiality of any information held by us and are trained to do so. However, we accept no responsibility if any unanticipated unauthorised access occurs. Cookies are pieces of information a Website can transfer to an individual’s computer hard drive. They are used by most Websites to help customise websites to suit a user’s needs. We are unable to control this usage.

Most internet browsers are preset to accept cookies, but you can change your preferences in your browser if you do not want information collected through use of cookies. However, disabling cookies might result in reduced website functionality.

RETENTION

We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we consider information is no longer needed and subject to any legislative requirement in respect of data retention, we will remove any details that will identify you or we will securely destroy the records.

INTERNATIONAL DATA TRANSFERS

If you are based in the EU, please note that it may be necessary for us to transfer your personal information to recipients in countries which are outside of the European Economic Area (e.g. Australia). Where any such transfer is necessary, we shall put in place appropriate safeguards to ensure that your personal information is held securely. If you require further information about the safeguards put in place you can request it from us by contacting us by email at the email address set out below.

ACCESS AND CORRECTION

We will endeavour to ensure that the information we hold about you is up to date and accurate. You are able to access the information that we hold about you at any time by emailing us at info@pronamics.com.au, by telephoning us on +61 7 3481 9666 or by completing the feedback form on our contact page. Please note that you will need to provide sufficient information (for example name, address, and contact details) to verify your identity and enable us to locate your records on our system. If you discover that information held about you is incorrect, please contact us to have the information corrected.

If you are based in the EU, you also have number of legal rights under the GDPR in relation to the personal information which we hold about you. We respect your legal rights in relation to your information and aim to uphold your rights in everything we do. Your legal rights under the GDPR include the following:

• Subject access right – You can ask us to provide you with a copy of the personal information which we hold about you and a description of how we use your information.
• Right to rectification – If you believe any information we hold about you may be inaccurate or incomplete, you can require us to rectify these inaccuracies.
• Right to erasure / Right to be forgotten – You can require us to erase your information in certain circumstances. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to data portability – Where we process your information using automated means of processing on the basis of your consent or for the purposes of performing a contract with you, you can request that we supply your information to another party in a machine-readable format.
• Right to restriction of processing – You can require us to restrict or suspend our processing of your information in certain limited circumstances.
• Right to object to processing – Where we process your information on the lawful basis that such processing is necessary for the purposes of our legitimate interests, you have the right to object to us processing your information in certain circumstances.
• Right to object to processing for direct marketing purposes – You have the right to object at any time to the processing of your information for direct marketing purposes. If you exercise this right to object, we will not process your information for such purposes.
• Right to withdraw consent – Where we process your information on the basis of your consent, you have the right to withdraw your consent at any time to the processing of your information. However, please note that this will not affect the lawfulness of any processing of your information carried out before you withdraw your consent.

PROBLEMS AND QUESTIONS

If we become aware of any ongoing concerns or problems with our website, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, or you have a problem or complaint (including with respect to our compliance with the Australian Privacy Principles), please email us at info@pronamics.com.au, telephone us on +61 7 3481 9666 or complete a feedback form and ask for our Privacy Officer appointed to look after these concerns. We will then consider your complaint and respond to you about it.

Nothing in this policy prevents you from making a complaint to the relevant privacy regulatory authority in Australia (namely the Office of the Australian Information Commissioner). If you are based in the EU, please note that you have the right to lodge a complaint with a relevant supervisory authority for data protection issues (e.g. in the UK the relevant supervisory authority is the UK Information Commissioner’s Office). For more information about privacy issues in Australia and protecting your privacy, visit the Australian Federal Privacy Commissioner’s website at www.privacy.gov.au.

CHANGES IN POLICY

The continued use of this website by you indicates that you acknowledge and agree to any future changes of our Privacy Policy. We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time. We suggest that you bookmark this page and check it regularly for any updates.

_{Version 21/01/2020 v.3.1}